Ask 10 people what fall protection means and you’re likely to get 10 different answers. For many in the construction industry, equipment is the first thing that comes to mind: personal fall-arrest systems, safety nets, or guardrails, for example.

Fall protection is more than just equipment. Fall protection is what you do to eliminate fall hazards and to prevent falls through employee training and documentation.

A contractor was recently visited by OR-OSHA who was interested in their fall protection program, specifically employee training. The employer had a fall protection program in their safety manual, a site specific fall protection plan and provided employee training records from tool box talks and completion of an OSHA 10 course.

Strangely, that was not enough for the inspector.

He wanted a detailed list of the fall protection topics covered in OSHA 10. While OSHA’s fall protection training requirements do include documentation, they are not as detailed as those requested by the inspector.

(1) Training Program 

(a) The employer shall provide a training program for each employee who might be exposed to fall hazards. The program shall enable each employee to recognize the hazards of falling and shall train each employee in the procedures to be followed in order to minimize these hazards.

(b) The employer shall assure that each employee has been trained, as necessary, by a competent person qualified in the following areas: (A) The nature of fall hazards in the work area; (B) The correct procedures for erecting, maintaining, disassembling, and inspecting the fall protection systems to be used;

(C) The use and operation of guardrail systems, personal fall arrest systems, safety net systems, warning line systems, safety monitoring systems, personal fall restraint systems, slide guard systems, positioning devices, and other protection to be used;

(D) The role of each employee in the safety monitoring system when this system is used;

(E) The limitations on the use of mechanical equipment during the performance of roofing work;

(F) The correct procedures for the handling and storage of equipment and materials and the erection of overhead protection; and

(G) The role of employees in the fall protection work plan;

(H) The standards contained in this subpart.

(2) Certification of training 

(a) The employer shall verify compliance with paragraph (a) of this section by preparing a written certification record.

The written certification record shall contain the name or other identity of the employee trained, the date(s) of the training, and the signature of the person who conducted the training or the signature of the employer.

Later this month, I will post a detailed list of all the NIETC safety related training topics. The list will document each subject and the extent that it is covered.  

Employers can add this to their employee training records to better handle OSHA inspections. Contact me if you have any questions.